Privacy Policy
Published Date: 28th July’2026
Document Description and Version Control
Document Name: Privacy Policy (PDPL-Compliant)
Published Date: 28th July’2026
Purpose of the document: The purpose of this document is to establish the legal framework for personal data processing in accordance with the UAE Personal Data Protection Law (PDPL). This document fulfills the mandatory transparency requirements where Lulu International Exchange acts as the Data Controller and Impronics acts as the Data Processor. It also defines the detailing of the technical processing of personal data and outlining the rights of data subjects.
1. INTRODUCTION
Impronics Digitech L.L.C-FZ (“Impronics”, “we”, “us”, or “our”), a free zone limited liability company registered in Meydan Free Zone, Dubai, UAE, is committed to protecting the privacy and personal data of users (“User”, “you”) of the Impropay platform. This Privacy Policy outlines how personal data is processed in compliance with UAE Federal Decree-Law No. 45 of 2021 regarding the Protection of Personal Data (“PDPL”).
2. ROLES AND RESPONSIBILITIES
2.1 Data Controller:
Lulu International Exchange L.L.C (“Lulu”), a CBUAE-licensed exchange house, acts as the Data Controller. Lulu determines the purposes and means of processing personal data for remittance and financial services.
2.2 Data Processor:
Impronics acts strictly as a Data Processor. We provide the front-end technology (UI/UX) and secure transmission protocols to facilitate the collection of data for Lulu. Impronics processes data only upon the instructions of the Controller or as required to facilitate the technical transmission.
3. DATA COLLECTION AND TRANSMISSION
The IMPROPAY application, developed and operated by Impronics Digitech LLC-FZ, collects only the minimum Personal Data necessary to facilitate the remittance services offered through Lulu International Exchange LLC. All data captured through the front-end interface is securely transmitted to Lulu via HTTPS/TLS encrypted communication channels, ensuring the confidentiality and integrity of the data in transit. The information retained is strictly limited to transactional response data generated by the backend processing system as a direct result of transactions initiated by the user.
4. LEGAL BASIS FOR PROCESSING
Processing is conducted based on:
- (a) The necessity to perform a contract to which the Data Subject is a party (facilitating the remittance request).
- (b) Compliance with legal obligations (AML/CFT requirements) handled by the Controller.
- (c) Consent provided by the User at the point of data entry.
5. USER RIGHTS (Data Subjects Rights)
Under the PDPL, Users have the right to:
- (a) Access their personal data held by the Controller.
- (b) Request rectification or erasure of personal data.
- (c) Restrict or object to processing.
- (d) Data portability. As Impronics do store the minimal user data and transmit the data in a secure manner to Lulu International Exchange L.L.C.
6. CROSS-BORDER DATA TRANSFER
Personal data may be transferred by the Controller (Lulu International Exchange LLC) to recipients located outside the United Arab Emirates where such transfer is necessary for the facilitation and settlement of international remittance services. All such transfers shall remain subject to the data protection safeguards required under the UAE Personal Data Protection Law (PDPL) and the regulatory framework of the Central Bank of the UAE (CBUAE), ensuring that an adequate level of protection is maintained at all times.
7. SECURITY MEASURES
Impronics implements industry-standard security measures, including OWASP Top 10 compliance, TLS 1.2+ encryption, and regular vulnerability assessments to ensure the integrity of data during transmission.
8. CONTACT
For UI-related privacy inquiries: